Information on the processing of personal data – direct marketing and training

This document provides you with information about your rights related to the processing of your personal data by Smart Energy Holding a.s., Company ID: 10676406, headquartered at U Trezorky 921/2, Jinonice, 158 00 Prague 5, or by controlled or controlling entities that, together with Smart Energy Holding a.s., form a group within the meaning of Sections 71-91 of Act No. 90/2012 Coll., on Commercial Corporations.

We recommend that you read the information carefully. We have done our best to make them as understandable as possible. If anything is still unclear to you, we will be happy to explain any term or provision to you.

1. Who is the controller of your personal data?

Smart Energy Holding a.s., Company registration No.: 10676406, with its registered seat at U Trezorky 921/2, Jinonice, 158 00 Prague 5, is the controller of your personal data (the "Data Controller"). Should it be necessary for the purposes of coordinating specialised training among the individual companies of the Smart Energy Holding a.s. group ("SEH") and joint marketing of the SEH Group, the Data Controller may also transfer your personal data within the SEH Group.

2. How are your personal data processed?

When processing personal data, we comply with applicable legal regulations, specifically Regulation (EU) 2016/679 of April 27, 2016, known as the General Data Protection Regulation ("GDPR"), and related legal provisions.

3. What is the purpose and legal basis for processing personal data?

We will process your personal data for the following purposes:

informing about future specialised training organised by the SEH Group;
informing about new products and services of the SEH Group;
performing obligations towards state administration authorities;
protecting the legitimate interests of the SEH Group members;
registration, statistical purposes.

Legal Basis for Personal Data Processing:

the legitimate interest of the Data Controller pursuant to Article 6(1)(f) of the GDPR - pursuing relations with business partners, providing customer care, sending commercial communications related to the service or goods offered or supplied by a member of the SEH Group (direct marketing);
performing a legal obligation as per Article 6(1)(c) of the GDPR;
for the purpose of inspections by state and local government authorities.

Your personal data that we process for the purposes of offering products and services to members of the SEH Group may be subject to analysing and profiling (but never automated) in order to tailor our offer to your needs. The personal data may also be used for marketing research carried out to optimise the products and services we provide to you and, where appropriate, to offer you customer benefits. We do not want to bother you with unnecessary and inappropriate communication. In particular, we will use your personal data that we process with your consent to better understand your needs and to be able to offer you a suitable solution in the form of products or services from the SEH Group members.

No automated decision-making or profiling shall occur during the personal data processing.

We process the personal data manually and automatically directly through our employees and, where applicable, data processors (as detailed below). The personal data protection is technically and organisationally secured by the Data Controller in line with the applicable legislation. The data processing shall not be carried out in a manner inconsistent with these purposes. Only data which are strictly necessary for that purpose are collected and processed.

4. Which of your personal data do we process?

For the above stated purposes, SEH processes the different categories of personal data, which may include as follows:

your name, surname, identification of your job position or relation to the affiliated company, your work e-mail address and, where applicable, your work telephone number.

5. Period of Your Personal Data Processing:

The processing of your personal data for marketing purposes will continue for the duration of our mutual business cooperation and as long as the effects of rights and obligations from the contract or during the provision of services with SEH or an associated company and/or member of the SEH group (hereinafter referred to as "relationship"), and additionally for the period necessary for archiving purposes under applicable mandatory legal regulations, but not exceeding the period stipulated by such regulations, and further for a period of 12 months following the termination of the relationship.

6. How do we protect your personal data?

You can be assured that we handle your personal data with due care and in compliance with applicable legal regulations. We secure your personal data to the maximum extent possible, corresponding to the technical level of available resources. SEH implements the following technical and organizational measures:

Physical access to SEH premises is restricted by locking entrance doors;
Protection of paper documents from unauthorized copying and use is ensured by storing them in locked cabinets and offices accessible only to selected SEH employees;
Electronic documents are protected by password-protected access, data encryption, and SEH network access is secured by a firewall.

When transferring your personal data outside of SEH, we contractually ensure an appropriate level of data protection and security in accordance with relevant legal requirements.

7. To whom else do we transfer your personal data and why?

We generally do not transfer your personal data outside of SEH except in cases where:

We have your consent;

It involves a member of the SEH group (especially PHOTOMATE s.r.o., Photomate Logistic s.r.o., Photomate Energy s.r.o., Prokišova s.r.o., PHOTOMATE Polska Sp. z o.o., Poland, PHOTOMATE Hungary Kft., Hungary, LLC PHOTOMATE, Ukraine, PHOTOMATE BULGARIA EOOD, Bulgaria, PHOTOMATE Scandinavia ApS, Denmark, PHOTOMATE Green Energy Romania Srl., Romania, PHOTOMATE Eurasia LLC, Georgia, Photomate Scandinavia AB, Sweden, organizational units of PHOTOMATE s.r.o. in Estonia and Lithuania, Photomate Kazakhstan, PHOTOMATE CA LLC, Uzbekistan);

Third parties acting as data processors on our behalf provide technical and organizational services, including software operation and data storage, and individuals providing accounting, tax services, or legal advice to the data controller according to our instructions;

We fulfill obligations imposed by legal regulations, which may involve financial authorities or other relevant authorities when required by mandatory legal provisions.

Except as outlined above, we do not intend to transfer your personal data to countries outside the EU or international organizations.

8. What rights regarding personal data protection can you exercise?

With respect to your personal data that we process, you have the following rights that you may exercise against us as the Data Controller:

right to obtain confirmation of the extent of your personal data processing and to access the data;
right to rectification or completion of your personal data if the personal data is inaccurate or incomplete;
right to erasure or restriction of the processing of your personal data if the conditions set out in the legislation are met;
right to object to your personal data processing;
right to transfer of your personal data to another data controller.

In the event that we process some of your personal data based on your consent, you have the right to withdraw your consent to the processing of such personal data at any time.

You may exercise all of your rights by submitting a written request to the Data Controller to the address of the SEH registered seat or by sending an e-mail to info@photomate.eu

Should you believe that the processing of your personal data violates the statutory regulations, you have the right to lodge a complaint with the competent EU national data protection authority.